## Agenda Item No.6

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------------------------------------------------------------|--------------------------------------------------------------------------|-----------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------| | Zoo Licensing Act 1981 (as amended) Zoo Licence for South Lakes Safari Zoo Ltd Non-Compliance with Direction Order – Public Walkways and Platforms | The Committee instruct the Zoo to close every public wooden walkway/platform, regardless of it’s height above the ground, until the full terms of the Direction Order have been met. | Immediate | Mr David Stanley Gill holds a zoo licence which was last renewed on 8th June 2010 to operate a zoo at premises known as South Lakes Safari Zoo Ltd, Crossgates, Dalton-in-Furness, LA15 8JR (“The Zoo”).\
At a meeting of the Licensing Regulatory Committee on 17th December 2015 the Committee resolved to elevate Condition No. 21 (Public Wooden Walkways and Platforms) to a Direction Order.\
A copy of the Direction Order was attached as an appendix for Member’s reference.\
The Direction Order required that all walkways and platforms to be closed to the public until the Direction Order was revoked.\
At a meeting of the Licensing Regulatory Committee on 4th February 2016 Members had:-

- Accepted a report from the Zoo compiled by R.G. Parkins and Partners Ltd that considered 2 out of an identified 7 elevated walkways and platforms. | The Direction Order served on the Zoo refers to all timber walkways and platforms. This includes those that are less than 300mm in height. No distinction has ever been made by the Committee in relation to the height of the walkways or platforms.\
  R.G. Parkins have confirmed they did not exclude any public wooden walkway or platform due to its height.\
  Members are aware that an inspection of the platforms/walkway was due to take place on 24th February, 2016 and delegated authority is in place which facilitates the removal of walkways from the Direction Order as and when compliance was achieved, therefore there was no long term imposition. | | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | platforms. | * Accepted that 5 out of the identified 7 elevated walkways had been, or were to be demolished and either remodelled or replaced. | | | | | | * Required an addendum to the report that the Zoo had completed the works specified by Parkins to ensure the remaining walkways were strengthened as directed and that other wooden structures being remodelled were suitable for that purpose. | | | | | | * Extended to time limit for compliance to 31st May 2016; and | | | | | | * Granted the Environmental Health Manager the delegated authority to authorise the walkways to open as and when the Zoo produced suitable evidence of the strengthening works. | | | | | | Following the service of the Direction Order relating to the public wooden walkways and platforms the Zoo was inspected by Environmental Health Officers on 20th January, 2016 to ensure that all the walkways were closed. |

### DECISIONS

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | Officers were accompanied by Ms Karen Brewer, the Zoo’s Marketing and Development Manager on the inspection. She stated that R.G. Parkins had informed her that walkways less than 300mm high did not need to be surveyed. | | | | | | It is accepted that a telephone conversation took place between Richard Garnett and Adam Roberts, Associate Director of RG Parkins on 11th February 2016 who stated that he had never advised the Zoo that a walkway less than 300mm should not be considered. This was also confirmed by e-mail. A copy of the e-mail exchange was attached as an appendix for Member’s information. | | | | | | The Zoo representatives attended the hearing and Ms Brewer made the following points:- | | | | | | * When the order was served we understood that the Zoo needed to get the report off RG Parkins before they could be reopened. | | | | | | * RG Parkins had employed a sub-contractor (CATG) and it was the sub-contractor who had suggested to the Zoo that walkways under 300mm were | | | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | not included in the Direction Order. | | | | | | * Since speaking RG Parkins, the Zoo have now completed the works to the two small sections and RG Parkins would be coming out to inspect on Wednesday 24th February 2016. | | | | | | * There is one other walkway that has not been closed which is a ground level walkway which provides wheelchair access from higher level to lower level which is about 5m in length. | | | | | | Mr David Gill, Licence Holder of South Lakes Safari Zoo Ltd attended the meeting and made the following points:- | | | | | | * The Zoo had previously recognised that some wood panels did need replacing but had made the business decision to replace all walkways to comply with guidance. | | | | | | * The Zoo were given clear information that any walkway under 300mm did not need inspecting. | | | | | | * The walkways have been replaced/removed to comply with guidance, not because they were dangerous. | | | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | * RG Parkins couldn’t understand why the standard had been imposed. Mr Gill could not produce evidence to support this assertion. | Members noted that British Standard BS 6399-1:1996 was in place at the time the first walkways/platforms were built. | | | | | * Mr Gill was unable to provide evidence that substantiated the oral assertion that other Zoo’s only have 300kg loading weight per square metre for their wooden platforms/walkways. | |

### Agenda Item No.7

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | David Stanley Gill, South Lakes Safari Zoo Ltd. Zoo Licensing Act 1981 (as amended) – Report on Periodical/Renewal Inspection | That the decision relating to the renewal application be deferred until 5th & 6th July 2016 and that proposed condition 32 be imposed. It was resolved that the existing licence should remain valid until the decision to extend is made at a hearing on 5th & 6th July 2016. Compliance date: 22nd May 2016 | N/A | On 11th January 2015 the Council received an application to renew the Zoo Licence from Mr David Gill. The current licence, in accordance with the Act, will expire on 6th June 2016. Zoo licences are renewable for a 6 year period. On 17th and 19th November 2015 a combined inspection was undertaken by 3 Secretary of State appointed inspectors, one of which, Mr Matt Brash, was in attendance at this 3 day Special Licensing Regulatory Committee. The Inspectors undertook a combined inspection comprising of a Periodical Inspection and Renewal Inspection. The Inspectors produced their statutory report of their findings for the Barrow Borough Council as the Licensing Authority. A copy of this report along with the reformatted report were attached as appendices for Member’s information. | Members considered whether the decision regarding renewal should be made at this hearing. The Committee noted the inspections team’s recommendation that Mr Gill’s licence should not be renewed unless the terms of proposed condition 32 were complied with, namely; “32. In order to comply with section 10 of the Secretary of States Standards, a robust management and staffing structure must be in place to the satisfaction of the licensing authority, in order to allow a new licence to be issued. This new structure must include a competent, suitably qualified and experienced full-time Director (or Senior Manager) with day to day responsibility for the running of the Zoo, the ability and authority to make decisions independent of the current owner (Mr David Stanley Gill), and must be fully responsible to the licensing authority for the conduct of the Zoo, all its on-site activities and its compliance with the Secretary of |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | | State’s Standards. [Please see recommendation/comment 2 regarding recommendation for refusal of a licence. Renewal of a licence is recommended to be dependent on the listed Additional Conditions being either complied with, or satisfactory progress towards compliance being made.] “ | | | | | | The Committee are mindful of the provisions in section 6 of the Zoo Licensing Act 1981, in particular sub-section 3 which states that any extension of an existing licence shall be granted for a period of 6 years. They form the view that rather than being forced into making a decision based on the Inspectors’ current views they would prefer to afford the Zoo every opportunity to positively react to the recommendations made in the Inspectors’ report in order to ensure that they are afforded every reasonable opportunity to extend their existing licence. Whilst the Act is silent on this point the Committee take the view that in the interest of fairness and proportionality it would be preferable to defer the decision on extending the licence until: | | | | | | a) the Zoo have been given a reasonable chance to implement meaningful change as required by the inspection team; |

The Inspectors recommended that the renewal of the licence be refused unless the “Additional Conditions” listed in their report are complied with, with greater emphasis placed on “Additional Condition 32”.

The report had been sent to the Zoo for comment on 22nd January, 2015. The Zoo provided their comments on 9th February, 2016 which were attached as an appendix for Member’s information.

Members noted that under Section 10(7) of the Act, the Zoo were given an opportunity to comment on the report, however these comments could not change the content of the original report.

Members noted the following legislation and guidance issued during their deliberations; The Zoo Licensing Act 1981, DEFRA’s Guide to the Zoo Licensing Act (2012 edition), SSSMZP and DEFRA’s Zoo Expert Committee Handbook (2012 edition)

The Inspection team had recommended that a new licence for South Lake Safari Zoo should | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | | b) the inspection team are given a reasonable opportunity to review the subsequent efforts of the Zoo and to report to the Committee accordingly; and | | | | | | c) for the Zoo to have a reasonable opportunity to consider the subsequent findings of the inspection team and to have their views heard at a subsequent hearing which will be held after the current licence has technically expired. | | | | | | Having considered the aforementioned and the necessary time required (having also taken into account other matters which are scheduled to take place in June 2016) it is the Committee’s view that a definitive and final view of the Zoo’s efforts could be considered on the 5th & 6th July 2016. | | | | | | In particular, it was considered reasonable and proportionate that the zoo be given sufficient time to demonstrate that a new and robust management and staffing structure was in place and that the conditions on the licence were being complied with. The Committee were mindful that in evidence at this hearing the Zoo submitted that management changes were taking place, and had been for some time, in the form of a charity being established, a board of trustees appointed and the appointment of a new |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | proposed number of licence conditions (33) sought in the report in to some form of context. | Chief Executive Officer. | | | | | Out of 165 zoo licences review a total of 47 (28%) had more than 12 conditions on their licence and could therefore be assumed to have had additional conditions imposed on their licences. | For the avoidance of any doubt it is the Committee’s view having considered the Inspectors’ comments that the full time experienced director or senior manager that will be responsible for the day to day running of the Zoo must be able to make unfettered decisions concerning the implementation of the requirements of the Zoo Licensing Act and associated guidance independent of the owner to ensure the welfare of the animals and the safety of staff and the visiting public. The Committee will be keen to identify that this role is full time and held by someone who will not spend large parts of the year absent from the site. In particular the Committee will be keen to receive adequate reassurances that whomever the person is who will have day to day responsibility for the running of the Zoo will not be the subject of unreasonable or disproportionate budgetary constraints which would otherwise effect their ability to implement and operate within the scope of what is required by the inspection team; the Zoo Licensing Act and any supporting statutory guidance. | | | | | Only 5% of zoos reviewed had over 20 conditions. | The Committee have noted that they have not been asked by officers to put in place the proposed condition 32 as suggested by the inspection team. However the Committee take the view that this | | | | | Members noted the Planning History of the Zoo in the form of a letter from the Development Services Manager which stated, amongst other issues, that there were currently several issues still outstanding relating to the new extension, a condition was yet to be discharged relating to the Marshalling Plan, the visitor reception building, the elephant house and a storage building adjacent to the highway appear to have been built in the wrong positions, a building at the west end of the Africa Paddock does not appear on the approved layout and the County Council were currently studying revised proposals relating to matters such as... | |

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## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | permanent signage and car park management. | condition should be added to the licence. In support of this decision the Committee sanction the imposition of proposed condition 32 to the licence to ensure that the licence has been noted with the requirements which are being placed upon the Zoo and its licence holder. | | | | | The Development Services Manager reported that retrospective applications had been requested to amend the previous approval, and for the new building, but at the time of writing, neither had been received. | | | | | | Members noted that it was not an offence to build without planning permission but it was an offence not to comply with an enforcement notice. | | | | | | Ultimately, this means that the entire extension, by virtue of non-compliance with the approved plan, could be deemed unauthorised and potentially liable to enforcement proceedings. | | | | | | Mr Gill was in attendance at part of the meeting and made the following representations:- | | | | | | * For the last 10 years he had run the zoo for only half of the year and Karen Brewer had been managing the zoo in his absence. | | | | | | * He had made a decision 3 years ago to retire to enable him to concentrate on | |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | his humanitarian work and that he would gift the operations of the Zoo to a charity. | | | | | | * There would be a board with a minimum of 10 trustees overseeing the operation of the Zoo. | | | | | | * Mrs Karen Brewer had accepted the role of Chief Executive Officer. | | | | | | * There would be a Management Team of 8. | | | | | | * He would have nothing to do with the Charity and would not be employed by the Zoo but stated that the Trustees had asked him to be an advisor during the period of change. | | | | | | * With regards to the Planning issues, Mr Gill stated that they had not misled anyone as the whole overview plan was sent to the Planning Department which was stamped and approved. | | | | | | * He stated that mortality rates at the Zoo were 10%. | | | | | | * He felt that the Zoo had not been given ample opportunity to correct any issues before they were escalated to conditions, and suggested that other Council’s work differently, thus, | |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | giving zoos chance to correct any problems. | | | | | | * 100 people’s jobs are at stake if the licence isn’t renewed. | | | | | | Representatives from the Zoo also attended the meeting and Ms Brewer made the following comments:- | | | | | | * It would be 7-10 days until there would be a meeting of the trustees. | | | | | | * Much of the paperwork had been signed but the legal documents still needed to change hands. | | | | | | * She asked how it would sit legally if there was to be a re-inspection in June and this was after the expiry date of the licence on 8th June, 2016. Mr O’Donnell informed the Committee that the existing licence would remain in place as the application would have already been submitted and that it would be a timetabling issue and suggested that the next special inspection should take place in May. | | | | | | * Ms Brewer submitted a written statement to the Committee on 2nd March, 2016 which was circulated to all Members. The statement reported | | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | that:- | | | | | | * There had been 2 additions to the team to replace David Gill’s 22 years of Zoo experience skills. | | | | | | * The new Company would be Safari Zoo Nature Foundation Limited (no registration number allocated as yet). | | | | | | * An application was in process to incorporate the Charity into a “not for profit” Company which was expected to be operational by 1st March, 2017. | | | | | | * She provided the names of the Trustees/Directors which were to be named on the application. | | | | | | * A further 6 Trustees/Directors were agreed by the Board for inclusion after incorporation, the names of which were provided. | | | | | | * The role of the Trustees/Directors was to oversee the existing mission statement, approve all activities, goals and objectives of the Charity both in its Zoo and Overseas conservation roles. | | | | | | * The Board had appointed a Zoo Chief Executive Officer, Ms Karen Brewer, who would be fully responsible for all Zoo activities and operations. | |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | * Ms Brewer’s role reports only to the Trustees/Directors and she was the only link between the Trustees who guide and approve all expenditure and policy and the Management Team who deliver the compliance, legal obligations and the recorded and agreed Board decisions of the Trustees/Directors. | | | | | | * The CEO will have total control over the Zoo staff in every aspect and will also have complete delegated responsibility to do all that is necessary to fulfil the Zoo Licensing Act (as amended). | | | | | | * The CEO is also fully responsible for delivering all Health and Safety compliance. | | | | | | * The CEO was the head of the Zoo Staff comprising 7 named positions along with 3 external veterinary contracts. Each member of staff was named. | | | | | | * The Safari Zoo Nature Foundation Ltd had a minimum 10 year legal contract to operate a Zoo on the site. | | | | | | * An application to transfer the Zoo licence from Mr Gill could not be made until it was fully incorporated. | |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | * Karen Brewer requested that the licence be renewed at today’s meeting to ensure confidence and continuity. This was later retracted and Karen Brewer requested that the decision be deferred to allow them sufficient time to demonstrate compliance with proposed condition 32 and the other imposed conditions. | | | | | | Mr Brash, the Defra appointed inspector also attended the meeting and made the following representations:- | | | | | | * Referring to Mr Gill’s earlier comments regarding not being given sufficient opportunity to correct any issues, Mr Brash stated that when zoo inspectors carry out an inspection for a Local Authority, they put on recommendations that should be done, not must be done. They then give the report to the Local Authority and if the Zoo enact on any of those conditions by the time the report is done they can be taken off the report. It was not unusual to work like this. | | | | | | * Members asked Mr Brash what | |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | qualifications would be need to be held by a Zoo Director. He replied by saying that it was not up to Inspectors to dictate what qualifications a Zoo Director held but they should prove that they are keeping up with modern zoo standards, were fulltime, managed the day to day running of the Zoo independent of the current owner and should be somebody with animal husbandry experience. | | | | | | * During the process it had become apparent that Mr Gill was overriding decisions made by the Management Team and it is of deep concern should the licence be renewed in Mr Gill’s name. | | | | | | * Should the new CEO and Management Team be allowed to, Mr Brash was hopeful that they could do a very good job. It is a very lovely zoo but it has just gone too far in some areas. | | | | | | * He would support the deferring of the decision of the renewal of the licence to a new Committee date but expressed to the Zoo that upon re-inspection, the Inspectors would be looking for whole hearted adoption of | |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A1 – Perimeter Fence | That the following condition be attached to the Licence:- In accordance with 8.7 and 8.29 of the SSSMZP all vegetation, shrubs, bushes and trees in proximity to the perimeter fence must be cut back and maintained to ensure they remain clear of the electric fencing. All shrubs, bushes and trees overhanging or near the perimeter fence must be kept cut back to prevent animals from escaping. | 22nd May 2016 | Escapes have been a long standing issue at the zoo. During the inspection a number of issues related to escapes or the potential of escapes came to the Inspector’s attention. The Inspectors noted considerable overgrowth of brush such as brambles which was short circuiting the electric fence and trees were overhanging the fence. These issues could aid escape. The Zoo submitted that the fence is checked daily and is always operational. A sample of the daily check sheets were made available to the Committee. The Zoo accepted the condition. | The perimeter fence is being compromised in several areas which lead to a number of potential escape routes for the free roaming of all small primates that inhabit the park. This is contrary to “statutory” Condition 3 of the existing licence. The Zoo accepted the condition. | | A29 – Black Tailed Prairie Dogs Escape Assessment | That the following condition be attached to the Licence:- In accordance with 8.10 and 8.29 of the SSSMZP, a suitable | 6 months | Members were informed that in the wild these animals live in extensive burrows and warrens. | According to Zoo Management the perimeter fence is shallow enough in this area for the prairie dogs to burrow underneath. This is contrary to Condition 3 of the Zoo’s licence which is a Section 1A condition. | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | | and sufficient written risk assessment carried out by a suitably qualified professional on the effectiveness of the perimeter fence must be undertaken and the recommendations be implemented. Copies of these reports must be sent to the Local Authority. | Condition 3 on the existing licence states that the Zoo must prevent escapes and put in place measures to be undertaken in the event of any escape or unauthorised release of animals. The Zoo advised that perimeter fence is only set into the ground to a depth of 30cm in this area. The Zoo commented that the Prairie dogs will be relocated over the next 24 months. Andrew Greenwood informed the Zoo that he is not qualified or able to write a risk assessment as requested. | “Preventing the escape of animals and putting in place measures to be taken in the event of any escape or unauthorised release of animals”. | | A7 – Hamadryas Baboon Indoor Accommodation | That the following condition be attached to the licence:- In accordance with 2.2, 4.3 and 4.4 of the SSSMZP, the indoor facilities for the baboons must be upgraded or replaced to meet the current recognised husbandry guidance. The indoor quarters must also allow for a developed programme of enrichment, e.g. deep straw litter and scatter feeding. | 22nd May 2016 | The baboons have access to a large outdoor enclosure which is shared with the rhino and giraffe. The indoor accommodation is a bare box with a sloping floor (higher at the front). It has no furnishings other than a single small screen, there is no climbing equipment, enrichment, bedding or any other items to keep the baboons engaged or exercised. The Inspectors describe the current facility as totally inadequate. The accommodation is small and offers no enrichment for the animals. This is contrary to Condition 2 of the zoo licence which is a s. 1A condition. Section 1A (c)(i) ZLA stated that the accommodation must meet the physical, psychological and social needs of the species. The wording of Condition 2 on the licence is:- “2. Accommodate and keep the animals in a manner consistent with the standards set out in SSSMZP”. |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A14 – Protection of Electrics from Animals | The Committee note that this matter has now been duly completed and witnessed as such by Council Officers and the Veterinary Inspector. | N/A | “insufficient”.\
S.1A(c)(i) requires “providing each animal with an environment well adapted to meet the physical, psychological and social needs of the species to which it belongs.”\
The Animal manager acknowledged that the accommodation is in need of enrichment in the shorter term and new accommodation in the longer term.\
The Veterinary Inspector advised that the baboons need bigger space indoors and better access to outdoors (of sufficient space).\
The Zoo stated that completion of the new Rhino enclosure was due to be completed on 1st May 2016 (although they envisaged this having to be extended) and the baboons would be moved mid-June 2016.\
The Zoo accepted the proposed condition. | The Zoo have taken all of the necessary steps to comply and have been witnessed as such by Council Officers and the Veterinary Inspector. |

The Animal manager acknowledged that the accommodation is in need of enrichment in the shorter term and new accommodation in the longer term.

The Zoo stated that completion of the new Rhino enclosure was due to be completed on 1st May 2016 (although they envisaged this having to be extended) and the baboons would be moved mid-June 2016.

Members noted that this has been an ongoing issue for some time and had been previously reported to the committee in June 2014. They therefore asked officers, the veterinary inspector and the zoo to meet during the adjournment to discuss what measures could be put in place immediately. They reached agreement, which was subsequently accepted by members that the Rhinos’ new enclosure would be completed by 1st April 2016 and they would be moved 3rd week in April 2016, following that the breeze block wall can be built and the baboons transferred to this enclosure.

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A17 – Public Barrier at Top Lemur House | The Committee note that this matter has now been duly completed and witnessed as such by Council Officers and the Veterinary Inspector and therefore, no condition will be placed on the Licence. | N/A | N/A | The Zoo have taken all of the necessary steps to comply and have been witnessed as such by Council Officers and the Veterinary Inspector. | | A19 – Shelters in Africa Field | That the following condition be attached to the Licence:- In accordance with 2.2 of the SSSM2P, shelter providing sufficient space for the accommodation of all of the animals having access to the African Field must be made available at all times. A written protocol detailing how this will be achieved must be made, adhered to, and a copy forwarded to the Licensing Authority. | 22nd May 2016 | On 23rd April 2015 an inspector asked to look at the recent arrival of a single male Nyala. The new building was not ready to receive animals however the zoo had taken collection of this Nyala. On 13th August 2015 it was report to the Committee that the Nyala arrived without the correct notification period being given. The Zoo argued these animals were difficult to obtain. The Nyala had access to a shipping container that had been placed in the field to act as a shelter. At the time of the inspection the Africa House was still incomplete and the number of | All animals in the Zoo must have access to a suitable outdoor shelter to resort to that provides a temporary refuge from the weather. The accommodation must be of a size to comfortably accommodate the number of animals being housed. The Veterinary Inspector asked that the recommendation/condition be changed slightly. The Inspectors were not suggesting 2 sets of shelters. Provided the zoo can confirm that the animals have access to the shelter at all times then there is no need for additional shelter. Works were ongoing to the rhino and giraffe house and the zoo need to confirm that they will have access whilst works are ongoing otherwise separate shelter will need to be provided. Officers and the Veterinary Inspectors met during adjournment to agree revised wording of the |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A20 – Flooring in the Caribbean Flamingo House | That the following condition be attached to the Licence:- In accordance with 2.2, 4.3 and 4.4 of the SSSMZP the floor in the Flamingo House must be the subject of review by the veterinary consultants and suitable flooring/substrate put in place to improve the health of the flamingos’ feet. | 6 months | The flamingos have been relocated to a new enclosure. They have a grassed outdoor area with a pool and indoor accommodation. The indoor accommodation has a formed concrete base with a foot pool. During the inspection on 17th & 18th November one of the Inspectors had noted that there were lame flamingos. | It is known that concrete flooring is detrimental to the soft feet of the flamingo, and predisposes them to developing foot lesions. This is contrary to Condition 2 of the zoo licence which is a s.1A condition and states: “2. Accommodate and keep the animals in a manner consistent with the standards set out in SSSMZP”. The Zoo submitted that they had written confirmation from Andrew Greenwood and Rick Browne that they had not treated any lame flamingos since April 2015. However, this written confirmation was not presented to the Inspectors at the time of the inspection nor to the Committee at the hearing. The Veterinary Inspector advised Members that the role of a collection vet is preventative as well as |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A21 – Review of Diets and Nutrition | That the following condition be attached to the Licence:- In accordance with 1.1, 1.12 and 1.13 of the SSSMZP a full review of diets and nutrition across all species, in consultation with the veterinary consultants, must be carried out. Records of all diets and the changes made must be documented and kept. | 22nd May 2016 | Diets are made up from food that would otherwise have gone into the waste stream from a major supermarket, fresh supplies and proprietary food from specialist suppliers. The dies had not been reviewed for some time. The Zoo accepted this condition and commented that meeting had taken place with the vet team, they were revisiting husbandry guidance, reviewing the diets and actions are in place. | There are a number of dietary issues such as feeding fruit to primates, and sunflower seeds to psittacine birds, where the Zoo appear to have fallen behind the current research. Whilst there is no criticism that the food being fed is of poor quality the Zoo needs to respond to changes in accepted good practice. The provision of a programme of nutrition, including food, water and dietary supplements, is a Section 1A mandatory condition. Members accepted that some work had been done however by the Zoo’s own admittance there was still a lot of work to do. | | A22 – Andean Bear Enclosure – Remove Pinch Point | The Committee note that this matter has now been duly completed and witnessed as such by Council Officers and the Veterinary Inspector and therefore, no condition will be placed on the Licence. | N/A | | The Zoo have taken all of the necessary steps to comply and have been witnessed as such by Council Officers and the Veterinary Inspector. |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A25 – Provision of a Wash Hand Basin in Meat Preparation Area | The Committee note that this matter has now been duly completed and witnessed as such by Council Officers and the Veterinary Inspector and therefore, no condition will be placed on the Licence. | N/A | N/A | The Zoo have taken all of the necessary steps to comply and have been witnessed as such by Council Officers and the Veterinary Inspector. | | A26 – Avoidance of Cross Contamination in Meat Kitchen | The Committee note that this matter has now been duly completed and witnessed as such by Council Officers and the Veterinary Inspector and therefore, no condition will be placed on the Licence. | N/A | N/A | The Zoo have taken all of the necessary steps to comply and have been witnessed as such by Council Officers and the Veterinary Inspector. | | A30 – Future Design of Enclosures | That the following condition be attached to the Licence:- In accordance with 1.5 and 5.1 of the SSSMZP the design of any new or remodelled accommodation for Category 1 animals must be sanctioned by a suitably qualified person and submitted to the Licensing Authority prior to the accommodation being built. The design must ensure that keepers do not have to enter an enclosure with a Category 1 animal. | Immediate | During the inspection on 17th & 18th November 2015 a keeper was observed by the inspectors walking in with a white rhino whilst moving the animal. During a subsequent inspection on 3rd February 2016 a member of staff was observed being in direct contact with 2 camels. Both these species are category 1 animals and non-protected contacted is potentially high risk. The Zoo were questioned by the inspectors regarding the plans for the new giraffe enclosures within the Africa House. The inspectors noted that to close the gates in the | There is a legacy within the Zoo that has failed to keep up with current thinking regarding keeper/animal contact. The designs for the new animal enclosures are often drawn up without keeper input and without adequate safeguards. As the Zoo designs new enclosures it is essential that the Zoo’s Veterinary Consultant approve these before the work starts so avoiding the issue of having to rebuild housing, such as has been done with the Andean Bear enclosure. In line with the new housing the Zoo will need to prove that changes in animal management are reflected in risk assessments and safe working practices. |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A33 – Yellow Anaconda Exhibit | That the following condition be attached to the Licence:-\
(a) In accordance with Paragraph 6.11 and 6.14 of Appendix 6 of the SSSMZP, the anaconda must be immediately removed off show and must only be returned on show in an enclosed unit; and\
(b) In accordance with 3.6, 8.13 and 8.14 of the SSSMZP, the pond located in the current anaconda facility must | Immediate | The anaconda lives in an open exhibit consisting of a pool surrounding vegetation.\
There is no barrier that would prevent a member of the public from touching either this reptile of the pond water within which it is housed.\
There is nothing preventing the snake from roaming freely within the whole enclosure.\
The snake is 2.5 meters in length and is currently classed as a category 2 animal. Once the snake becomes 3 meters n length or more it will become a category 1 animal. | (a) The keeping of the Yellow Anaconda, although still a Category 2 animal is in an enclosure that offers free access to the public and is not permanently manned by a member of staff. The Zoo have also given verbal consent as to what is being proposed; and\
(b) There is a risk to members of the public of disease transference from the stagnant water in the pond and there is a risk of drowning.\
(c) The Zoo failed to provide appropriate risk assessments. This is not compliant with SSSMZP 6.14.\
The Zoo stated they would take the anaconda off show with immediate effect until the condition |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A11 – Fly Killer in Vegetable Store/Kitchen | The Committee note that this matter has now been duly completed and witnessed as such by Council Officers and the Veterinary Inspector and therefore, no condition be placed on the Licence. | N/A | N/A | The Zoo have taken all of the necessary steps to comply and have been witnessed as such by Council Officers and the Veterinary Inspector. | | A9 – Removal of Photograph | The Committee note that this matter has now been duly completed and witnessed as such by Council Officers and the Veterinary Inspector and therefore, no condition be placed on the Licence. | N/A | N/A | The Zoo have taken all of the necessary steps to comply and have been witnessed as such by Council Officers and the Veterinary Inspector. | | A8 – Review of Public Feeding | That the following condition be attached to the licence:- In accordance with paragraphs 1.5 and 1.10, any organised sessions of members of the public preparing feeding animals that involves raw meat | Immediate | The Zoo offers an immersive experience for visitors with the opportunity to feed animal s in an unsupervised manner. There are also supervised feeding sessions through the purchase of wrist bands and extra experiences such as the feeding of the big cats. | The public are encouraged to feed the animals, both unsupervised, feeding food bought at the main entrance, and supervised during close encounters. Whilst the documentation states that the public should not encourage direct contact between the animals and the person feeding, in the Inspector’s opinion this is obviously going on. In fact the | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | | and fish must be the subject of a written risk assessment and protective gloves must be worn by all participants. | | The inspectors are generally supportive however the Zoo did not provide any evidence of any suitable risk assessments regarding the individual elements of the feeding experience. | photograph at the front entrance encourages it. Whilst the Inspectors would all agree that an immersive experience for people visiting zoos is generally a good idea, it is important that it is controlled, and that boundaries are not overstepped and that direct contact with the public must be restricted and controlled. Zoonotic disease prevention is paramount and the Zoo has a duty of care which cannot be passed onto the customer by expecting them to make an informed choice. The Zoo accepted that there is a risk of contamination to groups they consider vulnerable. Keepers have to wear gloves at all times. | | | | | During the inspection on 17th & 18th November 2015 the inspectors observed the keepers wearing gloves whilst preparing meat in the meat kitchen. | | | | | | | Matt Brash informed Members that there was a potential risk of contamination. | | | | | | | It was accepted by the Zoo that there is a risk of contamination to groups they consider vulnerable. They stated that keepers have to wear gloves at all times. | | | | | | | The Zoo made gloves available to members of the public, however they do not make it mandatory to wear them. | | | | | | | The Zoo charged 8 pence per glove unless they are identified as a high risk group such as pregnant ladies, children and persons with auto immune deficiencies. The Zoo stated that those persons are identified during the pre-feeding talk. | | | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | | | | A12 – Written Protocol for Quarantine of “rescue” Animals | In accordance with 3.19, 3.21 of the SSSMZP, written protocols must be reviewed with advice from the veterinary consultants, for the housing and quarantine of any animals introduced to the collection or accepted as rescue animals. Staff must receive training on the protocols and their implementation and this should be documented. | 6 months | The Zoo does not have an official policy on the acceptance of animals from the general public but it does deal with animals that the public “gift” them. Animals of this nature must be considered a potential high risk carrier of disease as they may not have undergone any levels of testing for infectious disease. The Zoo also has animals coming in from other collection as part of its development. During the inspection on 17th & 18th November 2015, Mr Brash observed that a cockatoo which had recently arrived was undergoing quarantine in the same area as | In accepting new animals to the collection, whether as temporary “rescue” cases or part of a formal development plan, the Zoo must be aware of the need to quarantine animals. There must be policies in place so that staff can house and care for the animals appropriately without risking the spread of disease throughout the current zoo population. Quarantine has been a significant problem in the past and the subject of enforcement, despite protocols being in place which indicates they are not being followed. |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | other birds. | | | | | | The Zoo commented that protocols were already in place and had been put before members in August 2015 and that this was purely a staff training issue. | | | | | | On 23rd June 2014 the ongoing issues relating to quarantine were reported to Members. Members were provided with supporting information from the AVHA (Animal Health & Veterinary Laboratories Agency). The AVHA had informed the Local Authority that the Zoo had been investigated and narrowly avoided prosecution relating to failing to comply with international quarantine rules for imported birds which were released from official quarantine early and without authorisation. | | | | | | Despite this intervention the Zoo did not provide a detailed and comprehensive protocol for quarantine management and the role of Veterinarians and Zoo Managers in complying with the law. | | | | | | AHVLA have also had considerable concerns over the veterinary management of the Zoo and for a period from January to March 2014 | |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | A24 – Review of Animal Bites | In accordance with paragraph 6.14 (Appendix 6) of the SSSMZP, a full written review of the risk of bites or injury to members of the public by animals must be carried out and an action plan adopted to eliminate bites and injuries. A copy of the report and the action plan must be forwarded to the Licensing Authority. In accordance with 8.14 of the SSSMZP, all contact injuries to visitors from animals must be reported to the Local Authority within 14 days. | 22nd May 2016 | The Zoo offers an immersive experience with the ability to walk through aviaries filled with free flying birds, feed certain animals, some supervised others not. During the inspection on 17th & 18th November 2015 the accident book was studied by the inspectors and they found that there had been 9 incident in 9 months. A king vulture had caused injury which was of great concern to the inspectors. A keeper was present at the time of the incident. The inspectors noted that in several areas including the Illescas Aviary, which houses the condor and vulture species, some animals were not afraid to approach humans. One of the inspectors had a black vulture perched on their wellington boot and was seen pecking at areas of mud. | The Committee have heard evidence of the risk of disease caused by animal injuries to members of the public. There have been 9 recorded injuries in 9 months. The Committee take the view that bites and injuries caused by animals are wholly unacceptable. Members of the public should have a legitimate expectation to not be at risk of any harm when visiting this attraction. |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | The Zoo informed the committee that the king vulture was a problem bird and had now been moved to Spain; that all incidents/accidents are reported to senior management team and a review is undertaken straightaway; that incidents happened when keepers are present is a training issue. | | | | | | The Committee were also informed by the Zoo that it wasn’t a child that was bitten, as reported by the inspectors, but an adult. They consider this more serious. | | | | | | 6.14 of the SSSMZP states that feeding should only take place when staff are present. | | | | | | Matt Brash states that the big aviary was not manned. This was acknowledged by Karen Brewer and advised that keepers are not present at all times, they are allocated as and when the need arises i.e. when the area is at its busiest. There is no set rota or numbers for the different feeding areas. | | | | | | Karen Brewer stated that they will consider manning at all times and that squirrel monkeys are not let out without staff present. | | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | She and David Armitage confirmed that there 22 squirrel monkeys. | | | | | | Karen Brew confirmed that when lemurs are let out they are not supervised in the same way as squirrel monkeys. Feeding of the lemurs doesn’t occur without staff present however bites have occurred when staff are present. David Armitage confirmed there are between 90 and 100 lemurs. | | | A10 – Lifebelt and Sign | Members note that Additional Condition 10 of the Inspectors’ Report has been complied with and that the completion has been approved by the Licensing Authority, therefore, does not require inclusion on the zoo licence. | N/A | Condition has been complied with to the satisfaction of the Licensing Authority and does not require inclusion on the Zoo’s Licence. | | | A15 – Enclosures Maintained to Protect Animal Safety | Members note that Additional Condition 15, of the Inspectors’ Report has been complied with and that the completion has been approved by the Licensing Authority, therefore, does not require inclusion on the zoo licence. | N/A | Condition has been complied with to the satisfaction of the Licensing Authority and does not require inclusion on the Zoo’s Licence. | | | A16 – | Members note that Additional | N/A | | Condition has been complied with to the satisfaction | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | Andean Bear Fencing | Condition 16, of the Inspectors’ Report has been complied with and that the completion has been approved by the Licensing Authority, therefore, does not require inclusion on the zoo licence. | N/A | of the Licensing Authority and does not require inclusion on the Zoo’s Licence. | | A18 – Temporary Enclosures in Africa House | Members note that Additional Condition 18, of the Inspectors’ Report has been complied with and that the completion has been approved by the Licensing Authority, therefore, does not require inclusion on the zoo licence. | N/A | Condition has been complied with to the satisfaction of the Licensing Authority and does not require inclusion on the Zoo’s Licence. | | A2 – Walkways | Members note that Additional Condition 2 was currently being dealt with separately and therefore does not require further consideration in this report. | N/A | Additional Condition 2 is currently being dealt with separately outside of this report. | | A4 – Zoonotic Infection/PPE | Members note that Additional Condition 4 was currently being dealt with separately and therefore does not require further consideration in this report. | N/A | Additional Condition 4 is currently being dealt with separately outside of this report. | | A28 – | Members note that Additional | N/A | Additional Condition 28 is currently being dealt with | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | Wire Mesh/Walkways | Condition 28 was currently being dealt with separately and therefore does not require further consideration in this report. | | | separately outside of this report. | | A6 – Redrafting of Existing Condition 14 (Hazardous Animals) | That existing Condition 14 of the Zoo’s Licence be replaced with:- “In accordance with paragraphs 5.1 and 10.1 of the SSSM2P all staff who work with newly arrived hazardous species (any animal listed in Category 1 of the Hazardous Animal categorisation (see Appendix 12 of the Secretary of State’s Standards of Modern Zoo Practice)) not previously held in the collection (or not within other staff’s past experience) must undergo a period of recorded training at a collection already holding the species. Evidence of this training must be forwarded to the Licensing Authority prior to the hazardous animal arriving on site. If staff have previous experience then | Immediate | As currently written the condition only refers to staff managing the animals, as opposed to all the keepers involved in the animals’ care. It also states that the training shall be agreed with the Licensing Authority which does not recognise that expertise may be held in-house by keepers with knowledge of similar animals. It was the Inspectors’ view that the wording could be simplified. The current condition does not specify that the training endorsement should be received before the animals arrive. In June 2014 this was raised as an issues and conditions 27 & 28 (suitably qualified staff training programme) were imposed on the licence. The Zoo accepted this condition. | The zoo licence conditions must be relevant to the premises, understandable by both the Zoo and the Authority, and must be enforceable. It is felt that by widening the scope of the training to cover all keepers involved, and stating that the training must be completed before the animal arrives, the condition is both clear in its objectives and enforceable should the need arise. The Zoo confirmed that they would fund all training courses. | | Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |----------------|----------|-----------|------------------|---------------------------------------------------------------| | | that experience must be detailed including dates and establishments where the training was received and forwarded to the Licensing Authority 4 weeks prior to the animal arriving. | | | | | A13 – Redrafting of Existing Condition 19 (Safe and Effective Control of Rodents) | That existing Condition 19 of the Zoo’s Licence be amended to:- “In accordance with 1.3a and 3.25 of the SSSMZP, a report covering the safe and effective control of rodent vermin and including recommendations is produced and submitted to the Local Authority by an independent, professional pest control company and an annual inspection to be carried out by the independent pest control company during each month of September and such report to be submitted to the Local Authority by no later than 31st October each year. | 6 months | During a special inspection on 28th & 29th January 2014 the inspection team saw and photographed evidence of a rodent infestation problem. During a limited special inspection the giraffe house did not reveal evidence of similar levels of rodent activity. An external company had been brought in to assist in developing a pest control plan. The control is currently being maintained in house by the keepers. On 20th August 2015 a pest control survey was conducted by Rentokil and a subsequent report recommended 5 courses of action. As a result of this survey the zoo changed the type of bait being use, added extra bait points and boxes, one members of staff from every section was responsible for control in their section. One person was specifically | There is evidence that the pest control in the dry food storage area specifically, and more generally throughout the park is still inadequate. The Zoo’s current pest proofing and baiting do not appear to be effective. It is required that an independent company inspect the Zoo to report on the current level of pest infiltration and to report on the requirement for proofing and baiting. The Committee heard of a longstanding problem with pest infestation. It is not a requirement that an independent company undertake the proofing or baiting. |

### DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|----------|-----------|------------------|---------------------------------------------------------------| | | | | employed and responsible for rodent control and an external course was undertaken by this person. In January staff training was implemented. They identified 2 members of the animal care team to drive the issue forward. | Through observation and discussion the Zoo has in place suitable arrangements to comply with the requirements of the Direction Order. | | | | | During the inspection on 17th & 18th November 2015 the inspection team noted and photographed considerable evidence of rodent infestation throughout many areas of the Zoo. | | | | | | The Inspectors recognise that some work has been undertaken to control vermin, however from the large scale evidence of the rodent problem, Inspectors still have a major concern that the current programme by the keepers is not effective. | | | Condition 20(a) – Remove Muck Heap and Relocate | The Committee record that the Direction Order is complied with and that Condition 20(a) be removed from the Licence. | N/A | Through observation and discussion the Zoo has in place suitable arrangements to comply with the requirements of the Direction Order. | | | Condition 25 – Clinical Waste Disposal Contract | The Committee record that the Direction Order is complied with and that Condition 25 be removed from the Licence. | N/A | Through discussion, the Zoo has in place suitable arrangements to comply with the requirements of the Direction Order. | |

## DECISIONS

| Agenda Item No. | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-----------------|--------------------------------------------------------------------------|-----------|---------------------------------------------------------------------------------|-----------------------------------------------------------------| | Condition 29 – Pygmy Hippo Pool | The Committee record that the Direction Order is complied with and that Condition 29 be removed from the Licence. | N/A | Through observation and discussion, the Zoo has undertaken all works necessary to comply with the requirement of the Direction Order. | | | Firearms | The Committee note this matter. | N/A | The Council is unaware of how the proposed transfer of the Zoo to a charitable status will affect the other licences held for the proper operation of the Zoo and the Committee will wish to be assured that the Zoo are considering such matters at the earliest opportunity. | | | A27 – Ethics Committee | Members note this issue as there is already an existing condition on the licence relating to the Ethics Committee. | N/A | The Zoo appreciate the need for an ethical review process and there is an existing condition on the Licence relating to this. | |

## Agenda Item No.8

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | Compliance with Conditions 17 and 18 – Direction Order | That the Committee escalate Condition 17 (Review of Veterinary Services) and Condition 18 (Delivery of Veterinary Services) to two Direction Orders as recommended by the Inspectors. This is not a Direction Orders requiring the Zoo to undertake works they would not normally be undertaking and therefore the Direction Orders will be effective immediately. The compliance date is 22nd May 2016 for both Orders. | Effective Immediately. Compliance date of 22nd May 2016. | Concern has been raised about the level of veterinary care over a number of years. It was raised at Periodical Inspections which took place on 9th November 2009 and 20th May 2013 and at a special inspection on 28th and 29th January 2014. Condition 17 was attached to the zoo licence on 8th June 2010 and Condition 18 in September 2013. On 1st July 2014 a Direction order was made in relation to Condition 18 (previously condition 25). In November 2014 the Direction Order was review, section 7 was deemed complied with and sections 8 and 9 were not considered further. At Special Inspection of 11th November 2014 and 26th February 2015 it was noted by the inspector that much work had been done to comply with the Direction. On 13th August 2015 it was reported to | The Committee have heard that the Inspectors have described the veterinary programme as inadequate and in need of radical revision to bring it in line with the requirements of SSSMZP. The Committee have heard that the Inspectors have also expressed their dissatisfaction with the current arrangements of veterinary services, in particular the lack of routine attendance. The Committee are also aware and concerned about the previous history of failures dating back to 2009 and that veterinary care has been subject of a Direction Order previously in 2014. The whole system from the keepers identifying a sick or injured animal, the treatment of the animals, and gross post mortem needs to be reviewed. The Zoo has to ensure that they are meeting the requirements of the SSSMZP but also the Veterinary Surgeons Act 1966 (as amended). | | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | Members that the Direction Order has been complied with. Members accepted this but agreed that the condition would remain on the licence. | | | | | | During the inspection on 17th & 18th November 2015 compliance with conditions 17 & 18 were assessed. The veterinary system was found to be “inadequate” and “needs to be radically revised” by the Inspectors. | | | | | | In view of recent previous non-compliance, the Licensing Authority sought further clarification from Mr Brash as to the evidential basis behind the Inspectors’ conclusion that the veterinary programme is inadequate and needs to be radically revised. His comments were as follows: | | | | | | 1. A written biosecurity program has put in place. However there is little evidence that much of this is being complied with. The Committee will wish to be aware of keepers cleaning enclosures without the correct protective equipment, which is being dealt with under the Health and Safety at Work Act 1974. | |

### DECISIONS

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | 2. | A health monitoring program has been established. A consultant zoo vet Andrew Greenwood FRCVS (AG) visits the collection once a month; however he does not provide a written report. A local vet, who is considered the collection vet, Rick Browne MRCVS, (RB) is meant to visit the collection once a week. However on interview he informed the inspectors that he does not attend every week, and when he does visit it is only for half an hour to forty five minutes. He does not undertake a routine walk round of the entire zoo. Although the addition of an expert zoo vet on a monthly visit is certainly a step in the right direction, this in no way practically fulfils the requirements and needs of such a large zoo, with its complexity of different animals. As the daily diaries show there is an animal that needs treatment of some kind or another on an almost daily basis. As a result the Inspectors believe that there is certainly a higher than expected mortality rate. A number of animals were observed by the inspectors that had medical conditions and had not received any level of veterinary |

### DECISIONS

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | attention. | | | 3. | Review of veterinary programme every six months. The special inspection in November 2014 had assured the inspection team that a programme had been put in place. However in November 2015 there was no documented evidence that this was being carried out and when the collection vet was questioned on this subject he agreed that no review was being undertaken. | | 4. | Accurate and detailed and comprehensive veterinary records must be maintained. At the last special inspection the person detailed to collate animal husbandry records was not available. However the inspection team were informed that process had been put in place, and that the system was now working effectively. | | | The process that the inspection team (November 2015) was informed was in place was that: | | | * Any animal showing signs of disease or illness would be reported to a senior keeper, and the problem noted | | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | in the daily diary | | | | | | * The senior keeper would then contact a veterinary surgeon, either AG or RB, and treatment agreed. If necessary a vet would attend, or treatment would be administered under the direction of the vet. | | | | | | * The use of drugs would then be recorded in the treatment book | | | | | | * The condition and treatment would then be recorded in ZIMS (Zoological Information Management System) | | | | | | If carried out this amply complies with the requirements of both the ZLA and the VSA. However during the Periodical inspection in November 2015 it was noted by the inspectors that this blatantly was not the process in place. A number of examples are given; | | | | | | 1. The daily diary has written on 23rd June 2015; Quote ‘Frieda says to keep an eye on Spooky skin’. The inspectors could find no reference to any veterinary input to this problem, nor to |

### DECISIONS

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | whom this referred. Nor was there any record in the vet book about this, or in ZIMS. | | | | | | 2. The Daily diary 29th June; Nyala lying down and rolling from side to side. It then says ‘Frieda says......’ There is no mention of any veterinary involvement and there is no recording of any abnormality or the illness in ZIMS | | | | | | 3. Since early 2015 six Nyala have arrived at the zoo, and five of these are now dead. Three of these occurred within a week of arrival, and a further two died in the week of the inspection, notably one on Sunday 15th and one on Monday 16th November 2015. When the directors were asked whether these two had undergone a post-mortem they were informed that they had been. Although a post mortem report had not been written up yet, the directors thought the cause was probably exposure. There was no evidence of any veterinary input into the treatment or post mortems of any of these animals. When the vets were questioned, neither knew of the death of the latest animal. Apart from the entries in the daily diary there are no other records relating to the period of time that |

### DECISIONS

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | these animals have spent at SLWP. There are no records within ZIMS as to the cause of death of the first three that have died. It should be noted that in the considered opinion of the vets that these animals might well have died from exposure, as all the animals in this mixed group were shut out whilst work was being undertaken in the building. However it is difficult to give a professional opinion as there was no post mortem report. | | | | | | 4. In the daily diary (Africa house) the notes on 4th July 2015 report that ‘the Equus africanus [Donkey] had two large swellings’. The day book then goes on to say that it has been given Tribrissen and Baytril (two different types of antibiotics). In the vet book there are no comments regarding this animal. In the vet drugs book it says that the animal received Tribrissen. In ZIMS it records that the animal received a course of Equipalazone (a pain killer). There was no recorded evidence that a vet has been involved at any stage in the process either in the diagnosis, management or treatment of this animal. | | | | | | 5. In the vet drugs book, many of the | |

Page 43 of 47 | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | drugs are signed as having been dispensed by either CF (Christine Fisher) or FS (Frieda Schreiber). Although some drugs have been signed as authorised by RB. It is illegal for a non-vet to diagnose, prescribe and dispense drugs to an animal. | | | | | | In the inspector’s opinion, although the collection has two vets, a local vet and an expert zoo consultant vet, they are not using them in the manner that the law dictates. From the records it appears that, although in some cases the vets are being contacted by phone, in many instances they are not, and FS and/or others are making decisions and dispensing drugs that only a qualified registered veterinary surgeon can do. | | | | | | Freida Rivera Schreiber explained to members her role and the process followed when she is notified of a sick animal. She stated that After being notified by a keeper she assesses the animal and decides whether they need to ring a vet. | | | | | | She confirmed that she cannot diagnose or administer medicines unless under the instruction of the retained vets. | | | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | When questioned about the record keeping she explain that when she arrived in 2014 there were no systems or programmes in place and there were very few post mortem reports despite having a full time vet. | | | | | | On advice from Rick Browne and Andrew Greenwood programmes and record keeping were reviewed. | | | | | | She agreed that there were mistakes between the keeper diaries and vet books. This was because 3 people were involved in the programme. | | | | | | In relation to the Nyala, for 3 of them there were no post mortems. She stated this was due to a mistake by a staff member. 2 post mortems were undertaken however these were not written up. | | | | | | When asked by Members she confirmed she was not seeking to qualify as a veterinary surgeon in the UK. | | | | | | Ms Schreiber confirmed that when David Gill was away for significant periods she was also | |

### DECISIONS

| Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | away. For approximately 3 months in total. | | | | | | When asked who was in charge when she was away she confirmed it was David Armitage and Christina Fischer. | | | | | | The Zoo had advertised for a full-time vet who would be employed by the Zoo. The current arrangement would remain until a replacement was found. | | | | | | Matt Brash informed members that vets dispense drugs for a particular animal. If there are surplus medicines left after treating the animal those drugs can be used for another animal. He stressed that non-vets are only allowed to administer drugs under the direction of a vet however the vet does not have to be present at the time they are administered. | | | | | | Mr Brash informed Members that at the inspection in 2014 there were no vets present. Information presented to the committee in 2015 was from the 2014 inspection. | | | | | | He explained the veterinary care is a not a fire | | | Title | Decision | Timescale | Findings of Fact | Reason for Decision & why alternative options were not adopted. | |-------|----------|-----------|------------------|---------------------------------------------------------------| | | | | Fighting role it is also preventative. | | | | | | In November 2015 the inspectors acknowledged that there was a process in place but it was not working. | | | | | | The Inspector reported that when inspected on Monday 22\\textsuperscript{nd} February 2016 there was a lot more evidence that there are more routine visits and paperwork however there was no evidence of sustained compliance. | | | | | | Mr Brash confirmed that a non-vet can undertake post-mortems but they cannot diagnose from that post mortem. | |